MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION. September 10, 2014 REVISED July 7, 2017 PERMIT TO INSTALL 97-14
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1 MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION September 10, 2014 REVISED July 7, 2017 PERMIT TO INSTALL ISSUED TO Henry Ford Hospital System LOCATED AT HFHS Rochester Hills Data Center 2571 Product Drive Rochester Hills, Michigan IN THE COUNTY OF Oakland STATE REGISTRATION NUMBER P0530 The Air Quality Division has approved this Permit to Install, pursuant to the delegation of authority from the Michigan Department of Environmental Quality. This permit is hereby issued in accordance with and subject to Section 5505(1) of Article II, Chapter I, Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Pursuant to Air Pollution Control Rule (1), this permit constitutes the permittee s authority to install the identified emission unit(s) in accordance with all administrative rules of the Department and the attached conditions. Operation of the emission unit(s) identified in this Permit to Install is allowed pursuant to Rule (6). DATE OF RECEIPT OF ALL INFORMATION REQUIRED BY RULE 203: August 11, 2014 DATE PERMIT TO INSTALL APPROVED: September 10, 2014 DATE PERMIT VOIDED: SIGNATURE: SIGNATURE: DATE PERMIT REVOKED: SIGNATURE:
2 Permit No Page 1 of 10 PERMIT TO INSTALL Table of Contents Section Page Alphabetical Listing of Common Abbreviations / Acronyms... 2 General Conditions... 3 Special Conditions... 5 Emission Unit Summary Table... 5 Flexible Group Summary Table... 5 Special Conditions for EUENGINE Special Conditions for FGENGINES... 8
3 Permit No Page 2 of 10 Common Abbreviations / Acronyms Common Acronyms Pollutant / Measurement Abbreviations AQD Air Quality Division BTU British Thermal Unit BACT Best Available Control Technology C Degrees Celsius CAA Clean Air Act CO Carbon Monoxide CEM Continuous Emission Monitoring dscf Dry standard cubic foot CFR Code of Federal Regulations dscm Dry standard cubic meter CO2e Carbon Dioxide Equivalent F Degrees Fahrenheit COM Continuous Opacity Monitoring g Gram EPA Environmental Protection Agency gr Grain EU Emission Unit Hg Mercury FG Flexible Group hr Hour GACS Gallon of Applied Coating Solids H2S Hydrogen Sulfide GC General Condition hp Horsepower GHGs Greenhouse Gases lb Pound HAP Hazardous Air Pollutant kw Kilowatt HVLP High Volume Low Pressure * m Meter ID Identification mg Milligram LAER Lowest Achievable Emission Rate mm Millimeter MACT Maximum Achievable Control Technology MM Million MAERS Michigan Air Emissions Reporting System MW Megawatts MAP Malfunction Abatement Plan ng Nanogram MDEQ Michigan Department of Environmental Quality (Department) NOx Oxides of Nitrogen MSDS Material Safety Data Sheet PM Particulate Matter NESHAP National Emission Standard for Hazardous Air Pollutants PM10 PM with aerodynamic diameter 10 microns NSPS New Source Performance Standards PM2.5 PM with aerodynamic diameter 2.5 microns NSR New Source Review pph Pounds per hour PS Performance Specification ppm Parts per million PSD Prevention of Significant Deterioration ppmv Parts per million by volume PTE Permanent Total Enclosure ppmw Parts per million by weight PTI Permit to Install psia Pounds per square inch absolute RACT Reasonably Available Control Technology psig Pounds per square inch gauge ROP Renewable Operating Permit scf Standard cubic feet SC Special Condition sec Seconds SCR Selective Catalytic Reduction SO2 Sulfur Dioxide SRN State Registration Number THC Total Hydrocarbons TAC Toxic Air Contaminant tpy Tons per year TEQ Toxicity Equivalence Quotient µg Microgram VE Visible Emissions VOC Volatile Organic Compound yr Year * For High Volume Low Pressure (HVLP) applicators, the pressure measured at the HVLP gun air cap shall not exceed ten (10) pounds per square inch gauge (psig).
4 Permit No Page 3 of 10 GENERAL CONDITIONS 1. The process or process equipment covered by this permit shall not be reconstructed, relocated, or modified, unless a Permit to Install authorizing such action is issued by the Department, except to the extent such action is exempt from the Permit to Install requirements by any applicable rule. (R (1)) 2. If the installation, construction, reconstruction, relocation, or modification of the equipment for which this permit has been approved has not commenced within 18 months, or has been interrupted for 18 months, this permit shall become void unless otherwise authorized by the Department. Furthermore, the permittee or the designated authorized agent shall notify the Department via the Supervisor, Permit Section, Air Quality Division, Michigan Department of Environmental Quality, P.O. Box 30260, Lansing, Michigan , if it is decided not to pursue the installation, construction, reconstruction, relocation, or modification of the equipment allowed by this Permit to Install. (R (4)) 3. If this Permit to Install is issued for a process or process equipment located at a stationary source that is not subject to the Renewable Operating Permit program requirements pursuant to R , operation of the process or process equipment is allowed by this permit if the equipment performs in accordance with the terms and conditions of this Permit to Install. (R (6)(b)) 4. The Department may, after notice and opportunity for a hearing, revoke this Permit to Install if evidence indicates the process or process equipment is not performing in accordance with the terms and conditions of this permit or is violating the Department s rules or the Clean Air Act. (R (8), Section 5510 of Act 451, PA 1994) 5. The terms and conditions of this Permit to Install shall apply to any person or legal entity that now or hereafter owns or operates the process or process equipment at the location authorized by this Permit to Install. If the new owner or operator submits a written request to the Department pursuant to R and the Department approves the request, this permit will be amended to reflect the change of ownership or operational control. The request must include all of the information required by subrules (1)(a), (b), and (c) of R and shall be sent to the District Supervisor, Air Quality Division, Michigan Department of Environmental Quality. (R ) 6. Operation of this equipment shall not result in the emission of an air contaminant which causes injurious effects to human health or safety, animal life, plant life of significant economic value, or property, or which causes unreasonable interference with the comfortable enjoyment of life and property. (R ) 7. The permittee shall provide notice of an abnormal condition, start-up, shutdown, or malfunction that results in emissions of a hazardous or toxic air pollutant which continue for more than one hour in excess of any applicable standard or limitation, or emissions of any air contaminant continuing for more than two hours in excess of an applicable standard or limitation, as required in Rule 912, to the Department. The notice shall be provided not later than two business days after start-up, shutdown, or discovery of the abnormal condition or malfunction. Written reports, if required, must be filed with the Department within 10 days after the startup or shutdown occurred, within 10 days after the abnormal conditions or malfunction has been corrected, or within 30 days of discovery of the abnormal condition or malfunction, whichever is first. The written reports shall include all of the information required in Rule 912(5). (R ) 8. Approval of this permit does not exempt the permittee from complying with any future applicable requirements which may be promulgated under Part 55 of 1994 PA 451, as amended or the Federal Clean Air Act. 9. Approval of this permit does not obviate the necessity of obtaining such permits or approvals from other units of government as required by law. 10. Operation of this equipment may be subject to other requirements of Part 55 of 1994 PA 451, as amended and the rules promulgated thereunder.
5 Permit No Page 4 of Except as provided in subrules (2) and (3) or unless the special conditions of the Permit to Install include an alternate opacity limit established pursuant to subrule (4) of R , the permittee shall not cause or permit to be discharged into the outer air from a process or process equipment a visible emission of density greater than the most stringent of the following. The grading of visible emissions shall be determined in accordance with R (R ) a) A six-minute average of 20 percent opacity, except for one six-minute average per hour of not more than 27 percent opacity. b) A visible emission limit specified by an applicable federal new source performance standard. c) A visible emission limit specified as a condition of this Permit to Install. 12. Collected air contaminants shall be removed as necessary to maintain the equipment at the required operating efficiency. The collection and disposal of air contaminants shall be performed in a manner so as to minimize the introduction of contaminants to the outer air. Transport of collected air contaminants in Priority I and II areas requires the use of material handling methods specified in R (2). (R ) 13. The Department may require the permittee to conduct acceptable performance tests, at the permittee s expense, in accordance with R and R , under any of the conditions listed in R (R )
6 Permit No Page 5 of 10 SPECIAL CONDITIONS EMISSION UNIT SUMMARY TABLE The descriptions provided below are for informational purposes and do not constitute enforceable conditions. Emission Unit ID EUENGINE1 EUENGINE2 EUENGINE3 Emission Unit Description (Process Equipment & Control Devices) A Cummins 2250 kw (3,280 hp) dieselfueled emergency engine generator set manufactured in A Cummins 2250 kw (3,280) dieselfueled emergency engine generator set manufactured in A portable rental Cummins 2000 kw diesel fueled emergency engine generator set. Installation Date / Modification Date TBD TBD Portable Flexible Group ID FGENGINES FGENGINES Changes to the equipment described in this table are subject to the requirements of R , except as allowed by R to R NA FLEXIBLE GROUP SUMMARY TABLE The descriptions provided below are for informational purposes and do not constitute enforceable conditions. Flexible Group ID FGENGINES Flexible Group Description Two (2) 2,250 kw (3,280 hp) diesel-fueled emergency engine generator sets. These engine generators must comply with 40 CFR Part 63 Subpart ZZZZ by complying with the requirements in 40 CFR Part 60 Subpart IIII. Associated Emission Unit IDs EUENGINE1, EUENGINE2
7 Permit No Page 6 of 10 The following conditions apply to: EUENGINE3 DESCRIPTION: A portable rental Cummins 2000 kw diesel fueled emergency engine generator set. Flexible Group ID: N/A POLLUTION CONTROL EQUIPMENT: N/A I. EMISSION LIMITS N/A II. MATERIAL LIMITS 1. The permittee shall burn only diesel fuel, in FGENGINES with the maximum sulfur content of 15 ppm ( percent) by weight. (R (1)) III. PROCESS/OPERATIONAL RESTRICTIONS 1. The permittee shall not operate EUENGINE3 for more than 500 hours per year on a 12-month rolling time period basis as determined at the end of each calendar month. The 500 hours includes the hours for the purpose of necessary maintenance checks and readiness testing as described in SC III.2. (R , R (a), R , R , 40 CFR (c) & (d)) IV. DESIGN/EQUIPMENT PARAMETERS 1. The permittee shall equip and maintain each engine of EUENGINE3 with non-resettable hours meters to track the operating hours. (R ) 2. The nameplate capacity of EUENGINE3 shall not exceed 2,000 kw as certified by the equipment manufacturer. (R ) V. TESTING/SAMPLING Records shall be maintained on file for a period of five years. (R (3)) N/A VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of five years. (R (3)) 1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor by the 30th day of the calendar month, for the previous calendar month, unless otherwise specified in any monitoring/recordkeeping special condition. (R , R , 40 CFR (c) & (d)) 2. The permittee shall monitor and record the total hours of operation of EUENGINE3, on a monthly and 12-month rolling time period basis, in a manner acceptable to the District Supervisor, Air Quality Division. (R )
8 Permit No Page 7 of The permittee shall keep, in a satisfactory manner, fuel supplier certification records or fuel sample test data, for each delivery of diesel fuel oil used in EUENGINE3, demonstrating that the fuel sulfur content meets the requirement of 40 CFR (b). The certification or test data shall include the name of the oil supplier or laboratory, and the sulfur content of the fuel oil. (R (1)) VII. REPORTING 1. Within 30 days after completion of the installation, construction, reconstruction, relocation, or modification authorized by this Permit to Install, the permittee or the authorized agent pursuant to Rule 204, shall notify the AQD District Supervisor, in writing, of the completion of the activity. Completion of the installation, construction, reconstruction, relocation, or modification is considered to occur not later than commencement of trial operation of EUENGINE3. (R (7)(a)) VIII. STACK/VENT RESTRICTIONS The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted: Stack & Vent ID Maximum Exhaust Diameter/ Dimensions (inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements 1. SVENGINE3 101 X R , R , R , 40 CFR (c) & (d) IX. OTHER REQUIREMENTS 1. EUENGINE3 shall not stay at the same location for more than 12 consecutive months. If EUENGINE3 remains at the same location for more than 12 consecutive months, then it will become a stationary source and this portion of the permit will no longer be valid. (R , R , R , 40 CFR )
9 Permit No Page 8 of 10 The following conditions apply to: FGENGINES DESCRIPTION: Two (2) 2,250 kw (3,280 hp) diesel-fueled emergency engine generator sets manufactured in 2013 and These engine generators must comply with 40 CFR Part 63 Subpart ZZZZ by complying with the requirements in 40 CFR Part 60 Subpart IIII. Emission Units: EUENGINE1, EUENGINE2 POLLUTION CONTROL EQUIPMENT: NA I. EMISSION LIMITS Pollutant Limit 1. NMHC + NOx 6.4 g/kw-hr 2. CO 3.5 g/kw-hr 3. PM 0.20 g/kw-hr Time Period / Operating Scenario Equipment Testing / Monitoring Method Underlying Applicable Requirements Test Protocol* FGENGINES SC VI.2 40 CFR , 40 CFR Test Protocol* FGENGINES SC VI.2 40 CFR , 40 CFR Test Protocol* FGENGINES SC VI.2 40 CFR , 40 CFR *Test Protocol shall determine averaging time. II. MATERIAL LIMITS 1. The permittee shall burn only diesel fuel, in FGENGINES with the maximum sulfur content of 15 ppm ( percent) by weight. (R (1), 40 CFR , 40 CFR (b)) III. PROCESS/OPERATIONAL RESTRICTIONS 1. The permittee shall not operate each engine of FGENGINES for more than 500 hours per year on a 12-month rolling time period basis as determined at the end of each calendar month. The 500 hours includes the hours for the purpose of necessary maintenance checks and readiness testing as described in SC III.2. (R , R (a), R , R , 40 CFR (c) & (d)) 2. The permittee may operate each engine of FGENGINES for no more than 100 hours per calendar year for the purpose of necessary maintenance checks and readiness testing, provided that the tests are recommended by Federal, State, or local government, the manufacturer, the vendor, or the insurance company associated with the engine. Permittee may petition the Department for approval of additional hours to be used for maintenance checks and readiness testing. A petition is not required if the owner or operator maintains records indicating that Federal, State, or local standards require maintenance and testing of emergency internal combustion engines beyond 100 hours per calendar year. Each engine of FGENGINES may operate up to 50 hours per calendar year in non-emergency situations, but those 50 hours are counted towards the 100 hours per calendar year provided for maintenance and testing. The 50 hours per calendar year for non-emergency situations cannot be used for peak shaving or to generate income for a facility to supply non-emergency power as part of a financial arrangement with another entity. (40 CFR )
10 Permit No Page 9 of If the permittee purchased a certified engine, according to procedures specified in 40 CFR Part 60 Subpart IIII, for the same model year, the permittee shall meet the following requirements for each engine of FGENGINES: a) Operate and maintain the certified engine and control device according to the manufacturer's emissionrelated written instructions, b) Keep a maintenance plan and the permittee may only change those engine settings that are permitted by the manufacturer. If you do not operate and maintain the certified engine and control device according to the manufacturer's emission-related written instructions, the engine will be considered a non-certified engine, and c) Meet the requirements as specified in 40 CFR 89, as it applies to you. (40 CFR (a)) 4. If the permittee purchased a non-certified engine or a certified engine operating in a non-certified manner, the permittee shall keep a maintenance plan for FGENGINES and shall, to the extent practicable, maintain and operate each engine in a manner consistent with good air pollution control practice for minimizing emissions. (40 CFR (g)(3)) IV. DESIGN/EQUIPMENT PARAMETERS 1. The permittee shall equip and maintain each engine of FGENGINES with non-resettable hours meters to track the operating hours. (R , 40 CFR ) 2. The nameplate capacity of each engine of FGENGINES shall not exceed 3,280 hp (2,250 kw for each generator set), as certified by the equipment manufacturer. (40 CFR , 40 CFR (a)) V. TESTING/SAMPLING Records shall be maintained on file for a period of five years. (R (3)) 1. The permittee shall conduct an initial performance test for FGENGINES within one year after startup of each engine to demonstrate compliance with the emission limits in 40 CFR unless the engines have been certified by the manufacturer and the permittee maintains the engine as required by 40 CFR Part 60 Subpart IIII. If a performance test is required, the performance tests shall be conducted according to 40 CFR No less than 30 days prior to testing, a complete test plan shall be submitted to the AQD. The final plan must be approved by the AQD prior to testing. Verification of emission rates includes the submittal of a complete report of the test results to the AQD within 60 days following the last date of the test. Subsequent performance testing shall be conducted every 8,760 hours of engine operation or 3 years, whichever comes first. (40 CFR , 40 CFR , 40 CFR Part 60 Subpart IIII) VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of five years. (R (3)) 1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor by the 30th day of the calendar month, for the previous calendar month, unless otherwise specified in any monitoring/recordkeeping special condition. (R , R , 40 CFR (c) & (d)) 2. For each engine, the permittee shall keep, in a satisfactory manner, records of testing required in SC V.1 or manufacturer certification documentation indicating that each engine of FGENGINES meets the applicable emission limitations contained in the federal Standards of Performance for New Stationary Sources 40 CFR Part 60 Subpart IIII. If any engine of FGENGINES becomes uncertified then the permittee must also keep records of a maintenance plan and maintenance activities. The permittee shall keep all records on file and make them available to the Department upon request. (40 CFR )
11 Permit No Page 10 of The permittee shall monitor and record the total hours of operation and the hours of operation during nonemergencies for each engine of FGENGINES, on a monthly and 12-month rolling time period basis, in a manner acceptable to the District Supervisor, Air Quality Division. The permittee shall document how many hours are spent for emergency operation of each engine, including what classified the operation as emergency and how many hours are spent for non-emergency operation. (40 CFR , 40 CFR ) 4. The permittee shall keep, in a satisfactory manner, fuel supplier certification records or fuel sample test data, for each delivery of diesel fuel oil used in FGENGINES, demonstrating that the fuel sulfur content meets the requirement of 40 CFR (b). The certification or test data shall include the name of the oil supplier or laboratory, and the sulfur content of the fuel oil. (R (1), 40 CFR (b)) VII. REPORTING 1. Within 30 days after completion of the installation, construction, reconstruction, relocation, or modification authorized by this Permit to Install, the permittee or the authorized agent pursuant to Rule 204, shall notify the AQD District Supervisor, in writing, of the completion of the activity. Completion of the installation, construction, reconstruction, relocation, or modification is considered to occur not later than commencement of trial operation of each engine of FGENGINES. (R (7)(a)) 2. The permittee shall submit a notification specifying whether each engine of FGENGINES will be operated in a certified or a non-certified manner to the AQD District Supervisor, in writing, within 30 days following the initial startup of the engine and within 30 days of switching the manner of operation. (40 CFR Part 60 Subpart IIII) VIII. STACK/VENT RESTRICTIONS The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted: Stack & Vent ID Maximum Exhaust Diameter/ Dimensions (inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements 1. SVENGINE R , R , R , 40 CFR (c) & (d) 2. SVENGINE R , R , R , 40 CFR (c) & (d) IX. OTHER REQUIREMENTS 1. The permittee shall comply with the provisions of the federal Standards of Performance for New Stationary Sources as specified in 40 CFR Part 60 Subpart A and Subpart IIII, as they apply to each engine of FGENGINES. (40 CFR Part 60 Subparts A & IIII) 2. The permittee shall comply with the provisions of the National Emission Standards for Hazardous Air Pollutants, as specified in 40 CFR, Part 63, Subpart A and Subpart ZZZZ, as they apply to each engine of FGENGINES. (40 CFR Part 63 Subparts A and ZZZZ, 40 CFR ) Footnotes: 1 This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
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